1094-B and 1095-B Filing Requirements – HRAs

In early August, the IRS released draft instructions for 1094-B and 1095-B that included HRA filing requirements. The final instructions released last week provide good news for employers that provide an HRA to their employees enrolled in their medical plan.

The final instructions state: An employer with an insured major medical plan and HRA coverage for which an individual is eligible because the individual enrolls in the insured major medical plan is not required to report the coverage under the HRA for an individual covered by both arrangements.

There are some exceptions; most notably if an individual is covered by an HRA sponsored by one employer and a non-HRA group health plan sponsored by another employer (such as spousal coverage). In this situation each employer must report the coverage the employer provides.

For details use this link to the IRS notice visit www.irs.gov/pub/irs-pdf/i109495b.pdf.

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